Nalls & Melvin v. State

In this opinion, we address challenges that have arisen since the issuance of our decision in Valonis & Tyler v. State, 431 Md. 551, 66 A.3d 661 (2013). In that case, we held that trial judges must comply with Maryland Rule 4-246(b) in order to accomplish the purpose of the Rule, that is, to protect the personal and fundamental constitutional right of a criminal defendant to a trial by jury. In light of this overarching principle, we address what constitutes a valid determination and announcement on the record that a criminal defendant’s waiver of his or her right to a jury trial was made…